MINUTES OF THE OPEN HOUSE SESSION “PROBLEMS FACED BY
PESTICIDES INDUSTRY IN THE PROCESS OF
REGISTRATION OF
PESTICIDES” HELD ON 19-05-2010 IN THE CONFERENCE HALL OF
CENTRAL INSECTICIDES LABORATORY (CIL), FARIDABAD
An open house session to deliberate upon the various issues and problems
of Pesticides Industry in the registration process of pesticides was held in the
Conference Hall of Central Insecticides Laboratory (CIL) at 11.00 AM on 19-052010 under the Chairmanship of Dr. Gurbachan Singh, Agriculture Commissioner
& Chairman, Registration Committee. Dr. P.S. Chandurkar, Plant Protection
Adviser to the Government of India, Shri S.K.G. Rahate, I.A.S., Secretary
(CIB&RC), experts from the secretariat of CIB&RC and representatives of various
Pesticides Industry Associations were also present.
At the outset Secretary (CIB&RC) extended a very warm welcome to
Agriculture Commissioner, PPA, representatives of different Pesticides Industry
Associations and experts of CIB&RC. He emphasized the importance of such an
interaction which was long overdue as it would serve as an effective platform to
have a first hand feedback on the various issues concerning the pesticide industry
thereby helping the system to gear up by improving its efficiency, accountability
and transparency. Later, Chairman expressed his gratitude and also extended a
warm welcome to all the participants who have come from far off places. The
presence of large number of participants from Industry Associations clearly
indicated the interest of the Industry for resolving the issues by sitting across the
table. Chairman also emphasized that the basic objective for conducting such an
open-house session is to crystallize and resolve the various issues/problems so as
to increase the transparency and efficiency in the pesticide registration system
which would ultimately result in the benefit of Indian farmers. He acknowledged the
tremendous contribution made by Pesticide Industry in Indian agriculture and
stressed that there is still enough potential to contribute to the overall growth of
agricultural productivity. Such an interaction helps in bringing together different
group having diverse opinion which ultimately would help in bringing more
transparency and improving the overall system to the satisfaction of all. After a brief
introduction by all the participants, Secretary, CIB&RC requested the
representatives of each Pesticides Associations to raise the issues concerning
them.
2.
List of participants is at Annexure-A.
3.
Issues raised by Crop Care Federation of India (CCFI)-
The representative of CCFI appreciated the initiatives taken by CIB&RC and
DAC for simplifying the registration process by doing away with the preliminary
scrutiny of applications u/s 9(4) Technical Import (TI), Formulation Import (FI) and
Formulation Indigenous Manufacture (FIM); Export Category and Extension of
Validity of Certificate of Registration (CR) of Biopesticides u/s 9(3B) of Insecticides
Act 1968; implementation of
online filing of registration of pesticides
(Computerized Registration of Pesticides-CROP). Thereafter, the following
suggestive measures were given by the representatives of Pesticides Industry
Associations:(i)
Organising such Open-House Session with the Pesticides
Associations at least once in every six months be institutionalized.
Industry
(ii)
The Guidelines for registration of technical import of pesticides are very old
and needs to be reviewed .
(iii)
Data on Metabolism Study on technical grade of pesticides with reference to
radio labelled compounds should be considered according to the studies
conducted with other methods due to advancement of science as is being
done and accepted in foreign countries.
(iv) The letter for ICAR comments should be sent parallel along with the scrutiny
under bioefficacy instead of sending the letter after the completion of scrutiny.
(v)
To avoid the reported lacing of several bio-pesticides with chemical
pesticides, an undertaking in the form of an affidavit may be asked from the
manufacturers of bio-pesticides.
(vi) Patent Act/Data Protection- Registration Committee should do away with this
condition and resolve this issue.
(vii) Registration Guidelines for use of surfactant with herbicidesThe
word
‘Registration’ should be replaced with ‘endorsement’ as it is a endorsement of
already registered herbicides with surfactant .
(viii) The cases for any kind of endorsement on Certificate of Registration and
Label/Leaflet claims may not be taken to RC.
(ix) Certain day-to-day operational issues were also raised for the information of
the house so as to find a suitable redressal.
(x)
The registration for import of formulation without registering technical should
be dispensed with in the interest of the Indian industry.
4.
Issues raised by Crop Life of India (CLI)
The representative of Crop Life of India appreciated the efforts of regulators
for streamlining and bringing transparency in the registration system by introducing
online registration of Pesticides. Thereafter, the following suggestions were made
by the representative:-
(i)
(ii)
(iii)
(iv)
(v)
(vi)
(vii)
(viii)
(ix)
5.
Facility of a preliminary Interactive Session with the concerned technical
expert be given before submission of applications U/s 9(3).
Issuing of Import Permit on priority to allow initiation of data generation well in
time.
Accelerated Storage Stability data should be allowed in registration of new
molecules which would fasten the registration process as is being done and
accepted in foreign countries.
ICAR comments should be dispensed with as the data submitted for
registration is generated through ICAR system and/or State Agricultural
Universities.
Revival of Guidelines for registration of safer formulation of pesticides
Standardization of Protocols for bioefficacy studies.
Streamlining of endorsement cases
Harmonization of Guidelines in accordance with OECD Guidelines.
To encourage introduction of new molecule in the country the guidelines for
Formulation Import without registering its technical should remain effective in
the overall interest of Indian agriculture.
Issues raised by Pesticides Manufacturer and Formulators Association
of India (PMFAI)
The representative of PMFAI appreciated the efforts made by the
Secretariat for bringing improvement in the registration system. Thereafter, the
representative submitted the following suggestions:(a)
The Guidelines for import of formulation without registering technical should
be dispensed with in the interest of Indian industry. This issue was also
raised in the Prasad Committee 2005 and the Committee also recommended
for doing away with these Guidelines.
(b)
Patent and Data Protection- This should not be allowed as the Patent Act is
dealt by different Ministry for different purpose.
(c)
Guidelines for new source - In the Guidelines the data on bio-efficacy is
required on all the crops. It was suggested that data on representative crops
only may be asked for under this category. They also suggested single
season bioefficacy data in place of two seasons.
(d)
In the Certificate of Registration issued for Export purpose in the caption ‘For
Export Only’ the word ‘only’ be deleted.
(e)
Technical Import for making its formulation for export be allowed in Export
Category.
6.
Issues raised by Confederation of All India Small & Medium Pesticides
Manufacturers Association ( CAPMA)
(a)
The representative of the Association has requested to extend the cut-off date
for on-line submission beyond 31-05-2010 as they are facing difficulty in ePayment of Registration Fee and requested for continuation of manual
submission of applications for registration for another few months.
The enclosures pertaining to establishment of bona-fide of the
manufacturers/firms like PAN Card, SSI registration, Company Incorporation
Certificate etc be stored in the data bank of the Registration Secretariat and
may not be asked from the applicant every time.
Removal of restriction for submission of three applications in a month U/s.9(4)
Category.
Removal of Consent Letter in case of FI and/or TI U/s.9(4).
In the guidelines of Technical Import from new source only one season data
on bioefficacy be allowed for acceptance instead of two season data.
In data requirement for formulation import, the environmental dependent
toxicology data should be dispensed with.
Patent Act/Data Protection- This should be stopped by RC. Let the matter be
taken up by the concerned Ministry governing Patent Act.
Dual Use Pesticides- Suggested for review of existing Guidelines.
Condition for two-year validity on Certificate of Registration be deleted.
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
7.
(i)
(ii)
(iii)
(iv)
Issues raised by Federation of pesticides Manufacturers’ Association
(SSI) (FOPMA)
The natural extracts are to be registered without much rigor. With Bioefficacy
and acute toxicity it can be registered as provisional registrants.
If food additives and drugs in large dose act as pesticide, they are suitable for
immediate registration, provided biological efficacy is produced.
Some brand new extracts will be good but to determine the chemicals in it
and structure may take time. And if they are satisfactory on other aspects
they can be registered. .
Industries at crossroads in pesticides and meaningful unorthodox approach is
needed. Regulatory authorities should not throttle natural innovation.
8.
Issues raised by Home Insect Control Association (HICA)
(i)
Suggested for separate channel/dispensation for scrutiny of applications for
house-hold insecticides.
Accelerated Storage Data be accepted for approving shelf-life of the product
for registration as is done in other countries which would reduce the currently
required time of two years to a mere two weeks.
At present data on bioefficacy is accepted from National Laboratories. It was
suggested that data be accepted from any GLP accredited laboratories.
(ii)
(iii)
(iv) In cases where inert ingredients/adjuvants are changed and a. i. remains the
same, such applications for registration should be considered without any
scrutiny.
(v) Speeding the process of issuing deficiencies, so that after rectification of
deficiencies Registration Certificates are issued at the earliest.
9.
(i)
(ii)
(iii)
Issues raised by All India Biotech Associations
To curtail the contamination of bio-products/bio-pesticides with chemicals an
undertaking be taken from the manufacturer/firms so that genuine
manufacturers should not suffer.
For granting extension in registration certificate of bio-pesticides U/s.9(3B) the
time period
should be counted from the date of issue of the extension
letter.
Since the research institutes like TNAU, IIHR, KAU etc., are engaged in
generation of data package for registration of bio-pesticides u/s 9(3B)&9(3)
and as they are not ready with the data package the cut off date i.e. 1st July
2010 for the implementation of new guidelines be extended by another one
year.
10. Issues raised by Haryana Pesticides Manufacturers Association (HPMA)
(i)
(ii)
(iii)
(iv)
(v)
(vi)
(vii)
(viii)
Request for generation of Bio-efficacy data for one season instead of two
seasons for registration of pesticides u/s 9(3) TI New Source.
Repeated trials on different animals pertaining to toxicological environment
dependent data for the same product may not be asked.
Registration for Formulation Import of pesticides without registering technical
grade is against the interests of Indian economy and the industry is engaged
in the formulation of pesticides. Hence, RC should do away with Formulation
Import.
Under the category Formulation Import (FI) Vs Formulation Indigenous
Manufacture (FIM) no data should be asked from the applicant for this
purpose.
Since India is a signatory to Patent Protection under WTO, data protection
should not be given to the MNCs.
Under Category 9(4) TIM the requirement for drawal in-process sample and
analysis in CIL be dispensed with.
The registration applications pending more than 6 months u/s 9(3) for want of
deficiency reply from the applicant should be rejected at the Secretariat level.
To curb illegal imports of pesticides and lacing of bio-pesticides with chemical
pesticides a stable mechanism be evolved at DAC level.
11.
Issues raised by Maharashtra Biocontrol
(i)
New guidelines for registration of bio-pesticides under different categories are
very harsh and requested for applying these provisions for registering new
molecules only.
(ii)
(iii)
The Secretariat of CIB&RC is not accepting the data on bioefficacy generated
by
other institutes except TNAU, IIHR, KAU.
Blaming contamination of bio-pesticides with chemical pesticide is
scientifically incorrect as chemical pesticides will affect the potency of the
so called contaminated bio-pesticide.
12. Issue raised by Gujarat Pesticides Association
Import of Formulation without registering technical should not be allowed in
the interest of Indian industry.
13. Issues raised by Andhra Pradesh Pesticides Manufacturers Association
(i)
(ii)
(iii)
Import of Formulation without registering technical should not be allowed
which is just an exploitation of Indian farming community and indigenous
manufacturers. There is no quality control of technical used for the
formulation being imported into India.
The requirement of a Consent Letter from source of technical import and
formulation import for registration u/s9(4) should be dispensed with.
Enclosures required for establishing the bona fide of the applicant under the
online filing of registration applications may not be asked every time from the
applicant. Once the bona fide of the applicant has been established with the
Secretariat a Unique Identification Number (UID) may be assigned which can
then be used in subsequent applications by the same applicant.
14. Bio Agri Pesticides Association (BIPA)
(i)
Since the research institutes like TNAU, IIHR, KAU etc., are engaged in
generation of data package for registration of bio-pesticides u/s 9(3B) & 9(3)
and as they are not ready with the data package for registration u/s9(3) the
cut off date i.e. 1st July 2010 for implementation of new guidelines be
extended by another one year.
(ii) BIS specifications may be formulated for allowing the level of contaminants in
bio-pesticides.
(iii) Separate guidelines may be formulated for registering botanical extract in case
they are required to be regulated under Insecticides Act 1968.
15.
Issues raised by MGR Industry Association
(i)
(ii)
(iii)
(iv)
(v)
Inadequacy in Form-I during e-filing of applications.
Review of guidelines for registration u/s 9(4).
Preliminary Scrutiny be dispensed with in all the categories of applications.
Speeding up of the pending Endorsement cases
Removal of two-year validity condition from Certificate of Registration u/s9(4).
After due deliberations on the above issues raised by various Industry
Associations, the issues can be classified into following three categories on
which action points that emerged are summarized below :A.
Common issues affecting industry Associations
I.
Metabolism study
There is requirement for accepting data on metabolism studies in plant
and animals with radio labelled technical grade material of the pesticides.
Industry Associations was of the view that with the advancement of
science certain new methodologies have come up for such studies. It
was decided that Industry Associations should provide base material
along with international scientific evidence for considering this issue in its
entirety by the Registration Committee.
(Action - Pesticide Industry Associations-CCFI )
II.
Accelerated Storage Stability study for shelf-life of pesticides
This was deliberated in detail and clarified that this study can be
accepted for granting provisional shelf-life for any product to be
registered to curtail time for registering any new molecule. However, the
applicant has to generate shelf-life of the product in ambient conditions
as per the requirement of Registration Committee guidelines for granting
regular shelf-life to the product.
(Action- As clarified by the Sectt. of CIB&RC)
III.
Primary Interactive Session with Experts of CIB&RC before filing
of applications.
Secretariat of CIB&RC has already fixed Tuesdays and Thursdays for
the pesticide industry representatives to visit the Secretariat and meet
experts/Secretary to discuss and seek clarifications on any issue
concerning the registration process. In fact it is a routine practice of
pesticide
industry
representatives
visiting
Secretariat
of
CIB&RC(Tuesdays & Thursdays) to discuss various issues including the
introduction of new molecules in India as per the need arising from time
to time.
As such, there is no need to frame any specific
guidelines/yardstick for this purpose.
Action- - As clarified by the Sectt. of CIB&RC )
IV.
Seeking ICAR comments
As per the existing practice the letter for seeking ICAR comments are
sent after the file is scrutinized and found complete from bio-efficacy
discipline. As per the decision of RC the ICAR comments should reach to
Secretariat of CIB&RC within 30 days. But mostly the ICAR comments
are delayed and the cases are pending in the Secretariat for
consideration of RC.
It is well known that the bio-efficacy data is
generated through ICAR and/or SAU system and the ICAR comments
are basically the verification of generation of this data from various
institutes. In order to avoid delays arising from the receipt of ICAR
comments, it is proposed that if ICAR comments are not received within
30 days, it will be deemed that ICAR has no comments to offer and the
case would be taken to RC for necessary deliberation/approval. This is
in consonance with RC decision taken in 222nd meeting.
Action- Secretariat of CIB&RC and Registration Committee)
V.
Harmonization of data requirement as per OECD and EU Guidelines.
This is very scientific and broad issue which needs to be discussed in a
group of high level scientists in the field of medical toxicology, chemistry,
bio-efficacy as well as environmentalists and scientists from Industry
Associations. Accordingly, a Committee may be constituted by the RC
for this purpose.
(Action- Registration Committee &Pesticides Industry
Associations)
VI.
Registration Certificates kept pending due to Patent issue
It was clarified by the Secretary that as on date no Registration
Certificates are pending due to any patent related issue. In an appeal,
recently heard by the Hon’ble Appellant Authority in the DAC, it has been
decided that Registration Committee cannot hold up the process of
granting the Registration Certificates on the basis of the patent
infringement claim. Thus, RC may issue a Certificate of Registration with
a stipulation that any liability arising out of an infringement of any other
law including the Patent Act 1970 shall be the sole responsibility of the
registrant. The above decision was in consonance with the advises
received from Department of Industrial Policy and Promotion (DIPP) and
Ministry of Law.
(Action- As clarified by the Secretariat of CIB&RC)
VII. Relaxation in bio-efficacy data in Technical Import/Formulation
Import - New Source Category
As per the existing guidelines two seasons multi-location data on bioefficacy is required for the above category of registration. Industry
Associations requested that one season data on bio-efficacy may be
accepted instead of two seasons.
A suitable justification along with
scientific justification/ basis may be submitted by the Pesticide Industry
Associations for the consideration of the Registration Committee.
(Action- Secretariat of CIB&RC and Pesticides Industry Associations)
VIII.
Issuance of Import Permit for Research, Test and Trial Purpose
(data generation)
The Pesticides Industry Associations were of the view that a lot of time is
being taken by the Registration Secretariat for issuing import permit for
research, test and trial purpose. This delay affects their planning and even
at times a crop season is missed for the required experimentation.
Accordingly, they requested that these applications may be scrutinized on
priority and a proper time frame be decided for this purpose. The Sectt. of
CIB &RC has taken adequate measures in expediting the issuance of import
permit for research, test and trial purpose. However, the applicant is
required to carry out the complete information with reference to quantity
required for carryout the test in respect of various disciplines along with
justification. Also, this
issue would be taken up for discussion in
Registration Committee meeting.
(Action- Pesticides Industry Associations and Registration Committee)
IX.
Patent and Data Protection
There have been diverse opinion of the Pesticide Industry Associations on
this issue. All Associations except Crop Life India opined that RC should
avoid interference in the Patent Act and Data Protection as appropriate
provisions have already been made in the said Act. A suitable justification
quoting the relevant provisions in the Patent Act may be submitted by the
Pesticides Industry Associations for taking appropriate decision by RC.
(Action- Pesticides Industry Associations)
B. Issues having policy ramifications
(i)
Import of formulation of pesticides without registering technical.
This issue was deliberated in detail. Most of the Associations except Crop
Life Association was of the opinion that formulation import of pesticides
without registering technical may not be allowed in the interest of Indian
farmers and Indian Pesticides Industry.
A suitable scientific justification
giving factual position may be submitted by the Pesticides Industry
Associations for taking appropriate decision by RC.
(Action- Pesticides Industry Associations and Registration Committee)
(ii)
Guidelines for Safer Formulations
In the past RC has formulated guidelines for registering safer
formulations of the already registered pesticides. But, there has been
problems in establishing the definition of safer formulation of an
insecticide. Thus, RC dispensed with the above guidelines. However, in
case Industry/Associations can submit some scientific justification as well
as criteria for identifying safer formulations, RC may reconsider this on
the basis of appropriate scientific justification.
Action - Pesticide Industry Associations and Registration
Committee )
(iii) Extension of date of implementation i.e., 1st July 2010 of new
Guidelines for registration of bio-pesticides.
Since the research institutes like TNAU, IIHR, KAU etc., are engaged in
generation of data package for registration of bio-pesticides U/s. 9(3B), 9(3)
and they are not ready with the data package for registration U/s.9(3) hence,
the cut off date i.e., 1st July 2010 for implementation of new guidelines be
extended for another one year. A suitable scientific justification giving
factual position may be submitted by the Pesticides Industry Associations for
taking appropriate decision by RC.
Action- Bio- Pesticides Industry Associations and Registration
Committee)
(iv) Evolution of mechanism to prohibit illegal import of pesticides and
lacing of bio-pesticides with chemical pesticides
This issue was deliberated in detail. Considering the sensitivity,
danger and illegal activities it was decided that a suitable proposal may be
submitted by Pesticides/Bio-Pesticides Industry Associations for curbing this
menace for further necessary action at appropriate level.
Action- Pesticide/Bio- Pesticides Industry Associations.
(v)
In the Certificate of Registration issued for Export purpose in the
caption ‘For Export Only’ the word ‘only’ be deleted.
This matter was raised by almost every Pesticides Industry
Associations that their members engaged in export of pesticides facing
difficulty with the caption ‘Export Only’ written on the Registration Certificate.
Therefore, they requested for removal of the word ‘Only’ from ‘Export Only’.
The appropriate decision in this regard would be taken by the Registration
Committee.
(Action-Registration Committee)
(v) Registration of Botanical Pesticides
Federation of Pesticides Manufacturers’ Association (SSI) (FOPMA)
requested that the natural extracts may be registered as provisional
registrants on the basis of bioefficacy and acute toxicity data and
emphasized
that regulatory authorities should not
throttle natural
innovation. This issue would be discussed in the Registration Committee.
Action-Registration Committee)
C.
Specific day-to-day issues
(i) Speedy issuance of 9(4) Certificates of Registration
(ii) Quick disposal of Endorsement cases
(iii) Grant of Import Permit on Priority for data generation
(iv) Standardization of UID system for establishing bona fide of
applicants
(v) Sorting of some teething problems faced by industry in E-Filing of
applications
The suggestions of the Pesticides Industry Associations on the above
points were noted.
Keeping in view the in-flow of applications for
registration and relevant workload the above issues will be reviewed at the
Secretariat level and appropriate measures shall be undertaken.
For the
issues pertaining to e-filing of applications, NIC shall be requested for
rectifying the same at the earliest.
Action- Secretariat of CIB&RC and NIC.
The meeting ended with vote of thanks to the Chair.
ANNEXURE-A.
LIST OF PARTICIPANTS OF OPEN HOUSE SESSION ON PROBLEMS FACED
BY THE PESTICIDES INDUSTRY ASSOCIATIONS IN REGISTRATION OF
PESTICIDES HELD AT 11.00 AM ON 19-05-2010 IN CONFERENCE HALL,
CENTRAL INSECTICIDES LABORATORY (CIL), FARIDABAD.
S.NO
NAME
Dr.
Singh
a. Gurbachan
1
DESIGATION/ORGANISATION
Agriculture
Commissioner
&
Chairman
(Registration Committee), Government of
India, Ministry of Agriculture
Plant Protection Adviser to the Government of
India, Directorate of PPQ&S.
2.
Dr. P. S. Chandurkar
3.
Shri S.K.G. Rahate, Director (PP) & Secretary, Central Insecticides
I.A.S.
Board & Registration Committee .
Dr. Sushil K. Khurana
Joint Director (Medical), Central Insecticides
Board & Registration Committee.
Dr.(Mrs.)Sandhya
Specialist Grade-I (Pharmacology), MOHFW,
Kulsreshtha,
Nirman Bhavan, New Delhi.
Dr. Hari Prasad
Joint Director (Chemistry), Central Insecticides
Board & Registration Committee.
Dr. A.K. Sinha
Joint Director (Plant Pathology), Central
Insecticides Board & Registration Committee.
Dr. B.S. Phogat
Joint Director (Weed Science), Central
Insecticides Board & Registration Committee
Dr. R.M. Shukla
Deputy
Director
(Entomology),
Central
Insecticides Board & Registration Committee.
Er. S.K.Ghosh,
Consultant,(Packaging), Central Insecticides
Board & Registration Committee
Shri Rajvir Singh
Deputy Director (Chemistry),
Central
Insecticides Board & Registration Committee.
Dr. Subhash Kumar
Assistant Director (Weed Science), Central
Insecticides Board & Registration Committee
Dr. Vandana Seth
Assistant Director (Chemistry),
Central
Insecticides Board & Registration Committee
Ms. Kamlesh Miglani
Assistant Director (Chemistry),
Central
Insecticides Board & Registration Committee.
Shri S.K. Sharma
S.O.(CIR.I), Central Insecticides Board &
Registration Committee
Shri S.K. Verma
S.O.(CIR.II), Central Insecticides Board &
Registration Committee
Sh. D.S. Sehrawat
PPO(Packaging),Central Insecticides Board &
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
Sh. Niraj Kulshrestha
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
Sh. R.D. Shroff
Sh. P.P. Dave
Dr. RBL Bhaskar
Sh. K.U. Kamath
Sh. KNG Mathan
Dr. M.P.Prasad
Sh. R.G.Agarwal
Sh. V.K. Agrawal
Sh. N.K. Aggarwal
N.N. Mishra
Dr. K.N. Singh
Ajit Kumar
S.N. Gupta
Raj Kumar Singh
Sh. Uttam Gupta
Sh.Rajesh Dhawan
Sh. Bhupender Sharma
Sh. S.S. Manhas
Abraham Mathew
Ravindranath S. Hegde
39.
40.
Sh. P.S. Rawat
Dr. Venkatesh Devanur
41.
Sh. Manjula T.R.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
Sh. Sanjay Gupta
Sh. Sanjay Jindal
Sh.Ramesh Bansal
Sh.Subhash Khurana
Sh. Pankaj Drolia
Dr.A. Sanyal
Dr. S.K.Biswas
Dr.S.Bedi
Dr.P.Roychowdry
Sh.Dinesh Prajapati
52.
53.
54.
55.
56.
Sh.S.S.Bhatnagar
Dr.Muralikrishna M.
Sh.Sushil Gather
Dr.Kusta Vaingankar
Sh. S.M. Ahsan
Registration Committee
Assistant (Legal), Central Insecticides Board &
Registration Committee
Chairman, CCFI
President, PMFAI
Adviser (Registration CCCFI matter)
HICA, Mumbai
Secretary, Home Insect Control Association
Home Insect Control Association(HICA)
Dhanuka Agritech Ltd.
MGRI Industry Association
HPMA (Haryana)
President, MGR Industries Association, Delhi.
Crop Care Federation
Crop Care Federation
CCFI
Regional Executive Director (PMPAI)
Resident Director, Crop Life India
Crop Life India (CLI)
Crop Life India
Rop Life India
Crop Life India/DuPont India
Crop Life India
(Makteshim Agan India)
United Phosphorus Ltd.
BIPA (BIO-Agri) Inputs Producers Association,
Hyderabad
BIPA (BIO-Agri) Inputs Producers Association,
Hyderabad
Member, Pesticides Manufacturer Association
-doMonsoon Agrochemical
President Pesticide Manufacturer Asso.,Karnal
Pesticide Manu.Association
P.I. Industries Ltd.
Indofil Chemicals Co.
Rice Co.International inc.
M/s.Sumitomo Chemical India Pvt. Ltd.
M/s.Punjab Chemical & Crop Protection
Ltd.,Mumbai.
M/s.Ecosense Lab, Mumbai.
M/s.Nagarjuna Agrichem Ltd.
M/s.Indofil Chemicals
M/s.P.I. Industries
-do-
57.
58.
59.
60.
61.
62.
63.
Dr.Vijay Jha
Dr. Anand Jha
Dr.M.Krishnan
Dr.Brij Uberoi
Dr.Suresh Pittehra
Dr.Sandeep Narwal
Sh.Ramesh Singh
64.
65.
66.
67.
68.
70.
71.
72.
Dr.B.V.Niranjan Kumar
Sh.Yatin J.Mokal
Sh. Ashwani Saluja
Sh.Vinod Bhatt
Sh.M.Rajamahender
Reddy
Sh.
Ganga
Sahay
Pathak
Sh.Jitendra Mohan
Sh.Vipin Saini
Sh.Gorakh Gadeker
73.
74.
75.
76.
77.
78.
Sh.Ramdas Patil
Sh. Rajendra Patil
Sh.Y.Nayudamma
Sh.K.K.Gupta
Sh.Soumen Khatua
Sh. Rajiv Dhingra
79.
80.
81.
82.
83.
84.
85.
86.
87.
Sh. Gunjan Verma
Sh. Anuj V.S.N.
Dr. V.K. Dingra
Dr.R.K.Singh
Sh.S.K. Misra
Dr. Rajeev Goel
Dr.S.Sundaresan
Dr.P.S.N.Srinivasn
Sh.Subhash Singh
69.
M/s.Rallis India Ltd.
M/s.UPL
M/s.Rallis India Ltd.
Crop Care Federation
M/s.Sulphur Mills Ltd.
M/s.Dow Agrosciences India Pvt.Ltd.
M/s.Punjab Chemicals & Crop Crop Protection
Ltd.
M/s.Dow Agroscience India Pvt. Ltd.
M/s.Cheminova
M/s.Yogi CropScience P.Ltd.
M/s.Agrochemical Association of India.
President CAPMA
Vice President Gujarat Pesticides Formulation
Association,Ahmedabad.
M/s. Willowood Chemicals
Member, CCFI
Member, Maharashtra Biocontrol Asso.,
Nashik
President ,Maharashtra BioControl Association
Vice Presidnet, MBMA, Nashik
Member, M/s. A.P.Pesticides Mfg .Association
M/s.Haryana Pesticides Mfg.Asso.
Member, M/s.Insecticides India Ltd.
Member, All India Biotech Association,New
Delhi.
Regulatory Affairs, M/s. Rickitt Benckiser
Marketing, M/s. Rickitt Benckiser (HICA)
ABMA, Hyderabad, Director Biorganics
M/s. Meghmani Agriscience
M/s.Crystal Phosphate
M/s.Crystal Phosphate
M/s.Ramcide(FOPMA)
-do-( FOPMA)
M/s.Dhanuka,Delhi.